Validity of Assessment u/s 153C: Reckoning the Limitation Period

Limitation under Section 153C: six-year period runs from receipt of seized documents, requiring assessment under Section 153C.

Where seized assets, documents and digital data recovered from a third party are found to relate to another person, the date on which the Assessing Officer having jurisdiction receives those seized materials is the deemed date of search for reckoning the six-year limitation period; that deemed date determines the relevant assessment year and which prior six assessment years fall under the special procedure for initiating assessments under Section 153C.